About
With effect from 1 January 2019, ships must report on the vessel's fuel consumption, time at sea and distance sailed to the vessel's flag state administration (or duly authorised organisation such as e.g. class societies) by 31 December every year. The aggregated annual data must be submitted in a standardised format and the methodology that will be used to collect the fuel consumption data and other information shall be included in the Ship Energy Efficiency Management Plan (SEEMP Part II).
Upon verification of the submitted fuel consumption data, the flag state (or duly authorised organisations) shall issue a Statement of Compliance, which must be carried on board the vessel. The flag state will be required to report the fuel consumption data to an IMO Ship Fuel Oil Consumption Database, and IMO will thereafter produce an annual report to the Marine Environment Protection Committee ('MEPC').
The IMO has implemented amendments to the IMO DCS, aimed at enhancing the granularity of the reports submitted under the IMO DCS. As of 1 August 2025, the amendments to the reporting requirements will be in force, requiring e.g. reporting of total fuel consumption per combustion system and actual transport work.
However, all data for the same calendar year are to be collected and reported with the same level of granularity. This entails that for existing ships currently reporting under IMO DCS, the amended data set should be reported starting from 1 January 2026 (from 1 January 2025 if the flag administration has agreed to an early implementation).
The amendments to IMO DCS will require a revision of the SEEMP in order to incorporate the new data collection requirements for the vessels.
During the 83rd MEPC session in April 2025 the committee approved draft amendments to make data more accessible to the public. The draft amendments involve that all reported data in the IMO DCS are accessible to Parties to Annex VI, in a non-anonymized form. An anonymized database (i.e., identification of a specific ship will not be possible) will be made accessible to public users.
Who does it impact?
Ship-owners or other companies or persons having assumed responsibility for the operation of a ship of 5,000 GT or above.
Status: In force
The IMO DCS was adopted by the IMO's Marine Environment Protection Committee on 28 October 2016 as amendments to Chapter 4 of MARPOL Annex VI, introducing a new Regulation 22A , which became effective on 1 March 2018.
There is an on-going process within the EU, in which the EU is considering to partly align the EU MRV Regulation to the IMO DCS.
Relation to other initiatives and regulations
The IMO DCS and the EU MRV Regulation are two similar systems, which run in parallel as long as the two regimes are not aligned.
The main differences are:
- The EU MRV Regulation focuses on emissions from shipping activities within the EU area, whereas the IMO DCS covers emissions from global shipping;
- The EU MRV Regulation requires reporting of actual cargo carried, whereas the IMO DCS uses ship DWT as cargo proxy;
- The EU MRV Regulation provides requirements for monitoring plans in a special format, whereas the IMO DCS requires a Part II of the SEEMP, called Ship Fuel Oil Consumption Data Collection Plan with its own given format;
- The EU MRV Regulation requires verification by an accredited body, whereas the IMO DCS requires verification by the flag state or a recognised organisation (such as, but not limited to, authorised class societies);
- Data under the EU MRV Regulation must be submitted through the Thetis system of EMSA, whereas the IMO DCS data collected are reported to the relevant flag state administration or recognised organisation; and
- Data reported under the EU MRV Regulation is published on a per-ship basis, whereas data reported under the IMO DCS is anonymously published by the IMO.
Participants
The IMO DCS applies to parties to MARPOL, Annex VI.
Thommessen's comments
The obligations under the IMO DCS are to be fulfilled on a 'per ship' basis and the fulfilling company can be either the ship-owner or any other company or person, such as a manager or the bareboat charterer, which has assumed the responsibility for the operation of the vessel from the ship-owner.
The IMO DCS data is used to calculate the ship's operational carbon intensity (CII).
The IMO DCS runs in parallel to the EU MRV Regulation, which both intend to quantify CO2 emissions from the shipping industry.
There are certain differences between the two regimes and if a vessel is subject to both the EU MRV Regulation and the IMO DCS, reporting must be made as the per the respective requirements.
The main differences are further described below.